Compliance/Code of Ethics

The Tokyo Electron Group acts in strict compliance with business ethics and applicable laws to ensure that its corporate activities are fair and trustworthy.

Business Ethics and Compliance

Basic Stance

Stakeholder trust is the cornerstone of business activities. In order to maintain trust, it is necessary to continuously act in rigorous conformity to business ethics and compliance. In line with the Fundamental Policies concerning Internal Controls within the Tokyo Electron Group, all Group executives and employees are required to maintain high standards of ethics and to act with a clear awareness of compliance.

Business Ethics

In 1998, Tokyo Electron formulated the Code of Ethics of the Tokyo Electron Group as a set of uniform standards to govern all of its global business activities. In the same year, the Company appointed a Chief Business Ethics Director and established the Ethics Committee, which is responsible for promoting business ethics awareness throughout the Tokyo Electron Group. The Ethics Committee comprises the Chief Business Ethics Director, the Ethics Committee Chairman, and presidents of major Group companies in and outside Japan. The members meet semiannually, report on ethicsrelated issues facing each company, and discuss measures to further improve ethical behavior and compliance. The Code of Ethics is reviewed in response to changes in the expectations of society. In January 2015, an anti-corruption statement was added to its introduction based on Principle 10 of the UN Global Compact, which concerns working against corruption including extortion and bribery. In August 2016, the Group revised the Code of Ethics in light of the Code of Conduct of the EICC ®* and broader social changes.The Tokyo Electron Group’s Code of Ethics and its Q&A section are published in Japanese, English, Korean and Chinese and disclosed on the intranet to enable all Group executives and employees, including those overseas, to view them at any time. The Code of Ethics is also publicly accessible from the corporate website.

Tokyo Electron has appointed a Compliance & Internal Control Executive Officer from among its executive officers to raise awareness of compliance across the Group and further improve Group-wide compliance. Each Group company has also drawn up its own compliance regulations, setting out basic compliance-related requirements in line with the Code of Ethics. The compliance regulations are intended to ensure that all individuals who take part in the business activities of the Tokyo Electron Group clearly understand the pertinent laws and regulations, international standards and internal company rules, and consistently apply these rules in all of their activities.

Compliance Education

Through the Group’s e-learning system, we provide web-based training programs covering the basics of compliance, exportrelated compliance, protection of personal information, the Act for Subcontracting and other topics. All executives and employees are required to complete these programs. In addition, other web-based programs tailored to specific positions and job roles are also available, including those on insider trading and the Social Security and Tax Number System. We also have a quiz-based business ethics and compliance education course, launched in fiscal 2014, for all Group executives and employees. Updated yearly, the quiz is intended to maintain compliance awareness throughout the Group and disseminate the latest information.In addition to these web-based courses, we organized inhouse seminars in fiscal 2017 for Corporate Directors and executive officers on the subjects of compliance and internal control.

Internal Reporting System

The Tokyo Electron Group has an internal reporting system that employees can use to report any activity suspected of being in breach of laws, regulations or business ethics. An ethics hotline and a compliance hotline have been established to receive reports from all Group companies, and each overseas location also has its own reporting system. In all instances, the system ensures that whistleblowers remain anonymous and are protected from any disadvantage or repercussions.There were no reports or cases of non-compliance with laws, regulations, or principles of ethics in fiscal 2017 that could have had a material impact on the Group’s business or local communities.

Confirming of Information on Japanese Laws

In order to reduce the risk of legal compliance violations, we regularly identify and clarify the Japanese laws that affect company operations and regulations. Information regarding revisions to relevant laws is received in a timely manner via an external Web service and appropriate responses are taken, such as amending internal regulations, changing operational procedures, and notifying all personnel affected by the revisions.